Compliance Controls and Monitoring

Select Cases

FCPA COMPLIANCE POLICY DEVELOPMENT AND MONITORING
Several large international corporations asked StoneTurn professionals to assist them in designing a comprehensive FCPA compliance program, including developing risk assessments, evaluating and designing FCPA policies, procedures and controls, and implementing robust ethics policies and codes of conduct. To ensure ongoing compliance, we set up tracking protocols for FCPA training and assisted in ongoing FCPA compliance monitoring and testing.

ACCOUNTS PAYABLE IMPROPRIETIES
A real estate development firm engaged StoneTurn to manage the collection, validation and analysis of multiple data sets to test for suspicious activities and trends in the accounts payable function. A suite of forensic analysis tests were performed on the company’s vendor and disbursement databases and reports were produced detailing areas of potential risk.

TRAINING FOR SALES & MARKETING, OPERATIONS AND FINANCE PERSONNEL
The Corporate Controller of an $8 billion global consumer products company retained StoneTurn professionals to develop anti-fraud and corruption training for sales and marketing, manufacturing, distribution and logistics and finance personnel. StoneTurn professionals developed and facilitated half day to two day training sessions customized for the client’s regional centers in Brazil, China, Netherlands, Poland, and the United States.

COACHING $50 BILLION PHARMACEUTICAL COMPANY ON FCPA AUDITS
The General Counsel, Corporate Controller and Chief Audit Executive of a $50 billion pharmaceutical company retained StoneTurn professionals to coach internal auditors on conducting FCPA audits. Working alongside the client’s staff, the team provided hands on training on assessing corruption risk, testing anticorruption controls and auditing for corruption red flags. The training enabled the client to become entirely self-reliant.

ASSESSMENT OF $70 BILLION MANUFACTURER’S ANTI-FRAUD & CORRUPTION PROGRAM
The Chief Audit Executive of a $70 billion global industrial manufacturer retained StoneTurn professionals to assist in the evaluation of how the organization addresses fraud and corruption risk. The StoneTurn professionals applied a framework based on criteria from the DOJ, SEC, PCAOB, USSG, IIA and COSO. The team interviewed dozens of employees and prepared an audit committee report, which Chief Audit Executive subsequently shared on a redacted basis as a model for conducting these evaluations.

FRAUD RISKS & CONTROLS REGISTERS
Chief financial officers, compliance officers, audit executives, and risk officers of companies in the banking and capital markets, asset management, health care provider, health care payer, insurance, retail and consumer, energy and industrial manufacturing industries engaged StoneTurn professionals to facilitate fraud and corruption risk assessments. StoneTurn professionals developed an inventory of schemes based on their subject matter expertise, industry research, client brainstorming and focus groups, business reviews and past incidents of the client. The team assessed likelihood, significance and the adequacy of existing processes and controls relied upon by the organization to prevent and detect misconduct.

$10 BILLION TRANSPORTATION COMPANY INCIDENT RESPONSE & REMEDIATION PROGRAM
The Chief Audit Executive of a $10 billion diversified transportation company retained StoneTurn professionals to revamp its processes for responding to allegations of misconduct and taking action to prevent recurrence. After interviewing the client’s in-house investigators, reviewing a sample of investigative files and benchmarking against comparable organizations, the team provided the client with a step-by-step blue print for overhauling the incident response program.

BIG 5 CANADIAN BANK GOVERNMENT MONITORSHIP
StoneTurn professionals were project leaders of a three-year monitor ship of “Big 5” Canadian bank compelled by regulators to engage an independent third party monitor. The team interviewed senior members of the bank to understand the original issue and controls implemented by the client to prevent recurrence. The team observed client meetings, tested controls and issued periodic reports to the Canadian regulators and to a monitor appointed by the U.S. Department of Justice.